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Case 1:15-cv-07433-LAP Document 1325-14 Filed 01/04/24 Page 7 of 30 in multiple locations. So she and her legal counsel have worked diligently to track them down through a search that has spanned nearly two decades and two continents. Ms. Giuffre made her initial disclosures on this subject in an answer to an interrogatory that she served on April 29, 2016. Ms. Giuffre listed 15 health care providers that she could recall at the time. Four days later, on May 3, 2016, Defendant deposed Ms. Giuffre. During the deposition, Ms. Giuffre’s memory was jogged and she was able to recall two additional providers: Judith Lightfoot and Dr. Christopher Donahue.° Defendant, however, seeks to magnify the innocent recollection of two additional providers at Ms. Giuffre’ deposition by misleadingly claiming that “[i]t is only through deposition testimony that Ms. Maxwell became aware of at least five - if not more - treating health care physicians.” (Mtn. at 1). This claim, too, is inaccurate. Beyond Ms. Lightfoot and Dr. Donahue, Defendant apparently adds to the list of “withheld” doctors by referring to treating physicians who cared for Ms. Giuffre on a one-off basis in the Emergency Room. It is unsurprising that a patient would have trouble remembering an emergency room physician’s name. But the real point here is that, in any event, the information was disclosed through documents produced, so there is absolutely no “failure to disclose” as Defendant wrongfully alleges. See Centura Health Records (GIUFFRE005498-005569). Defendant then states that, in her deposition, “Ms. Giuffre claims she was not treated by any other physicians,” and then states that other records revealed “three additional health care ° Defendant’s argument that Ms. Giuffre was trying to “hide” these providers is illogical and wholly contradicted by the fact that Ms. Giuffre disclosed these providers. Defendant never explains how Ms. Giuffre can be “hiding” providers while testifying about them and producing their records.